June 5, 2020

NEWS & UPDATES
MANUFACTURED CANNABIS SAFETY BRANCH
Licensees and Stakeholders –

It has been 10 weeks since the COVID-19 Stay at Home order went into effect, and the State is now on a path to reopening. We’ve included updates below on what you can continue to expect from our office and some reminders for maintaining safe and sanitary conditions in your manufacturing facility.

Across the State and nation, we have seen protesters advocating for reforms to address social inequities. We’ve heard concerns from many of you about the risk of burglary for cannabis businesses – some not associated with peaceful protests but, rather, appearing to be the work of opportunistic criminals. Tips are included below for maintaining the security of your facility and about what to do if you experience a theft or loss.

Our staff is still working, and we’re here to support you. Please don’t hesitate to email us if you have any questions or need anything.

Stay healthy. Stay safe.

The Manufactured Cannabis Safety Branch team
COVID-19 UPDATES
GMPs and Sanitary Practices
Even as the State begins to reopen, extra precautions are still needed to ensure the safety of your workforce and to maintain a sanitary production environment. Remember to practice Good Manufacturing Practices, such as hand washing and frequent cleaning of surfaces, and to incorporate State and local guidance for screening and social distancing of employees.

How to Prepare for an Inspection
One of the most common questions we hear from licensees is: What can I do to prepare for my inspection? To answer that, we developed a checklist of some of the key facility, process and document requirements that are checked during an inspection. This checklist can also be used between inspections for a quick assessment of compliance.

Modifications to Inspection Processes
Our inspectors have begun conducting some inspections remotely in an effort to facilitate COVID-19 social distancing for both licensees and our team. If you are due for an inspection and eligible for a remote inspection, a member of our inspection team will let you know. Here’s an overview of how remote inspections will be conducted:
  • An MCSB inspector will contact you by email and/or phone. Note: All MCSB inspectors have a State government email addresses that ends in @cdph.ca.gov.
  • The inspector will ask you to complete a questionnaire and provide pertinent facility and operations records in order to start the process.
  • Engage with your inspector to provide the necessary records and information.
  • A video call may also be included as a component of your remote inspection.

Completing the Self-Inspection Checklist will help you prepare for a remote inspection.

Our inspectors continue to make visits to manufacturing facilities when a physical presence is needed. If an MCSB inspector contacts you to schedule an on-site inspection or visits your licensed facility, you must grant them access to the premises.

License Fee Deferrals
Cannabis manufacturers with licenses expiring during the month of June are eligible to request 60-day deferrals for payment of their license fee. The document below contains instructions for requesting a deferral, or for making any other type of disaster relief request:

FAQs about COVID-19
We posted answers to some of the more commonly asked questions that have arisen during COVID-19. Those questions include:
  • Are there any mandatory quarantine/holding periods for finished goods due to COVID-19?
  • Are Live Scan requirements suspended while Stay at Home orders are in effect?
  • Can I adjust the amount of gross annual revenue I report on my license renewal application to reflect a possible future loss of revenue?
  • Can I complete the required Cal/OSHA general industry training online?

Visit the COVID-19 page of our website for answers to these questions and more: www.cdph.ca.gov/mcsb/covid19 . We’ll continue to update this page over time. 
PREMISES SECURITY AND THEFT
Notification of Theft or Diversion
If theft or diversion has occurred on your cannabis manufacturing premises, you must notify MCSB and law enforcement within 24 hours of discovery. We have assembled a quick guide with instructions for how to notify us. We’ve also created an optional form to assist you with providing the key information.

We understand that having a theft at your business can be an unsettling experience. Don’t worry if you don’t have all of the information right away – just make sure you notify us. Our team will walk you through the process from start to finish, from inventorying the losses to making the appropriate adjustments to your track-and-trace records.

Tips for Securing Your Premises
While it is impossible to prevent all criminal activity, having an up-to-date Security Plan ( §40200 ) can reduce risk of unauthorized access. Below are some steps you can take to minimize losses, protect the safety of employees, or help with investigations when you experience theft:

  • Use commercial-grade locks on exterior doors. Using commercial-grade, non-residential locks can make it harder for an intruder to break through the door. 
  • Secure windows and other entry points. Take steps to minimize the potential that someone can enter the premises through a window. 
  • Use a security alarm system. Security alarm systems that record breaches of the premises can be a key notification and investigation tool.
  • Reconcile your inventory at least every 30 days. Having an up-to-date list of your inventory will help you identify what was stolen.
  • Make sure your security cameras are on and recording. Security camera recordings are a critical tool in identification and investigation of theft. Remember that recordings must be kept for a minimum of 90 days. 
  • Ensure your cameras cover all key areas on your premises. Recordings of the interior and exterior of all points of entry into the building or premises, as well as all areas in which cannabis is manufactured or stored, can help with identification and investigation.
  • Have clear lines of sight in the area surrounding your premises. Cut back hedges or other vegetation so that there are fewer hidden spots around the exterior of your building. 
ABOUT THE MANUFACTURED CANNABIS SAFETY BRANCH
The California Department of Public Health’s Manufactured Cannabis Safety Branch (MCSB) is one of three state licensing authorities charged with oversight of commercial cannabis activity in California. MCSB is responsible for licensing and regulating cannabis manufacturers and for establishing statewide standards for packaging and labeling of cannabis and cannabis products.

MCSB strives to protect public health and safety by ensuring commercial cannabis manufacturers operate safe, sanitary workplaces and follow good manufacturing practices to produce products that are free of contaminants, meet product guidelines and are properly packaged and labeled.

www.cannabis.ca.gov               www.cdph.ca.gov/mcsb                  MCSB@cdph.ca.gov